San Francisco v. Sheehan

Brief Filed: 2/17/2015
United States Supreme Court
Year of Decision: 2015

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Whether the Americans with Disabilities Act requires police officers to make reasonable accommodations when arresting an armed intellectually disabled individual.

Disabilities/Rights under the ADA

Teresa Sheehan lived in a group home for persons with intellectual disabilities. Her social worker summoned the police after Sheehan threatened to kill him. The social worker told the two responding officers that Sheehan was schizophrenic. They entered Sheehan’s room but then retreated when she threatened them with a knife. The officers radioed for backup but then decided to re-enter the room before the backup arrived. When they re-entered, Sheehan again threatened them with a knife. The officers pepper-sprayed Sheehan and shot her several times, though she survived.

Sheehan sued the officers and the city, alleging claims under: (a) the ADA, (b) the Fourth Amendment, and (c) state law. (The state-law claims are not relevant here and are not discussed further.) Regarding the ADA, the Ninth Circuit held that the statute applies to law enforcement officers who are attempting to arrest a disabled individual, and further held that there was a triable issue here of whether the officers failed to reasonably accommodate Sheehan’s disability when they re-entered her room forced their way back into her room without taking her disability into account or employing generally accepted police practices for peaceably resolving a confrontation with a person with an intellectual disability. Regarding the Fourth Amendment, the court held that the officers’ first entry into Sheehan's room was reasonable as a matter of law, but that there were triable issues about the reasonableness of their re-entry as well as about whether their use of force was excessive. The court also held that the offers were not entitled as a matter of law to qualified immunity on the Fourth Amendment claim.

APA joined an amicus brief in support of Sheehan that was authored principally by the American Psychiatric Association. (The brief was also joined by the National Council on Disability, the National Alliance on Mental Illness, the Bazelon Center for Mental Health Law and five state Psychological Associations.) The brief supports Sheehan's position that the ADA applies to (at least some) arrests of armed intellectually disabled individuals, and explains that as an empirical matter, making reasonable accommodations in such circumstances is entirely feasible. In particular, the brief explains that law enforcement groups around the country have already adopted a variety of specialized approaches to dealing with intellectually disabled individuals — approaches that experience has shown benefit the disabled individuals as well as the officers involved. The case will be argued on March 23.

On May 18, 2015, the Court held that public officials are entitled to qualified immunity unless they have violated a clearly established constitutional or statutory right. A right is not clearly established unless a reasonable official in that public official’s shoes would have understood his actions to be in violation of that right. In this case, the officers’ second entry into Sheehan’s room without a warrant did not violate the Fourth Amendment because law enforcement officers may enter a home without a warrant in an emergency situation when there is potential for injury to the occupant. The Court also held that the officers’ use of force was reasonable under the circumstances, even to the extent of firing multiple rounds.